Crump v. Saul, No. 18-3491 (7th Cir. 2019)Annotate this Case
Crump applied for social security disability benefits based on her long history of numerous mental health impairments, including bipolar disorder and polysubstance abuse disorder. An administrative law judge denied benefits, finding that Crump, despite her severe impairments, could perform work limited to simple and repetitive tasks. The district court affirmed. The Seventh Circuit vacated. The ALJ did not adequately account for Crump’s difficulties with concentration, persistence, or pace in the workplace. An ALJ generally may not rely merely on catch-all terms like “’simple, repetitive tasks’” because there is no basis to conclude that they account for problems of concentration, persistence or pace. In addition, observing that a person can perform simple and repetitive tasks says nothing about whether the individual can do so on a sustained basis. Beyond disregarding the Vocational Expert’s opinion in response to a second hypothetical, the ALJ gave short shrift to the medical opinions of Crump’s treating psychiatrist.